Financial Services Spotlight

Action Required Under the Volcker Rule by January 22, 2017

Posted by Roy Andersen on Dec 14, 2016 12:00:00 PM

Action Required Under the Volcker Rule by January 22, 2017.

Late Monday afternoon, the Fed announced that banks may seek an extension of time (up to five years) to hold and presumably arrange to sell their investments in or holdings of so-called “illiquid funds” that were made impermissible under the Volcker Rule.  Under the most recent relief before Monday, these investments had to be “conformed” or sold by July 21, 2017.  Many banks and banking interest groups had complained to the Fed that a variety of hedge funds and private equity funds were sold and operated to invest in “illiquid” assets and that forced sales of such investments before maturity would be a financial burden.

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Topics: Dodd-Frank, Banking, Illiquid Funds, Investment, Volcker Rule

February 2016 Second Half Developments

Posted by Roy Andersen on Feb 29, 2016 12:00:00 PM

Overview

Old acronyms die hard.  No less an authority than a senior attorney at the Federal Reserve Bank of New York advised me that no one calls the Bureau of Consumer Financial Protection the BCFP—even though this is what it is called in the Dodd-Frank Act.  Instead, even the agency refers to itself as the CFPB.  Accordingly, we will get in step for future entries, as we have with the Met Life Building, the Ed Koch Bridge, and Kennedy Airport.  A rose by any other name would smell as sweet.  The OCC continues to study its leveraged lending guidelines.   Foreign swap transactions executed in the U.S. will benefit from some exemptions.  The healthy dividend paid by the Fed to the member banks will be cut back based on new law adopted in January.  

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Topics: Libya, Dodd-Frank, Cuba, CFPB, Foreign Transactions, Leveraged Lending, Reserve Banks, OCC, BCFP, No-Action Letters

About the Spotlight


The Financial Services Spotlight examines the regulatory and technology developments impacting banks, asset managers and other financial services providers—where challenges meet opportunities.

 

Meet the Authors


Roy C. Andersen, of counsel in Sullivan & Worcester's New York office, is a member of the Corporate Department. Mr. Andersen focuses on bank regulatory and compliance matters, including international banks and their branches and agencies in New York.

Joel Telpner, partner in the firm's New York office, is a seasoned advisor, strategist and problem solver. Mr. Telpner brings more than 30 years of legal experience in a career that includes time as an AmLaw 100 partner, the former U.S. general counsel of a global financial institution, and a venture capitalist. He is recognized for his ability to deftly manage complex financial transactions, especially those involving sophisticated structured finance and derivatives matters and has an extensive and unique combination of transactional and regulatory experience.

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